Barbara Strozzilaan 336
1083 HN Amsterdam
The Netherlands
gssbsecretariat@globalreporting.org

Item 07 – GRI Universal Standards
Project – Public comment feedback
on reporting principles
For GSSB information
Date

8 February 2021

Meeting25 February 2021

Project

GRI Universal Standards Project

Description

This document contains an extract of public comments related to Section 4.
Reporting principles in GRI 101: Using the GRI Standards in the Universal
Standards exposure draft, which was made available for public comment between
11 June and 9 September 2020.
The document presents the comments received via the online survey and via
letters, for GSSB reference.
Note to reading the comments:
Comments have been included verbatim. Where a respondent has raised several
distinct points in one comment, each point has been numbered and presented in a
separate row. The point number is indicated in brackets before the verbatim
comment. In addition to this, comment numbers have been included in the firstcolumn to help facilitate the discussion during the meeting on 25 February.

This document has been prepared by the GRI Standards Division and is made available to observers
at meetings of the Global Sustainability Standards Board (GSSB). It does not represent an official
position of the GSSB. Board positions are set out in the GRI Sustainability Reporting Standards. TheGSSB is the independent standard setting body of GRI. For more information visit
www.globalreporting.org.

© GRI 2021

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Public comments

2

Please refer to pages 18-23 in the Universal Standards exposure draft.

3

Table 1. Comments on Section 4. Reporting principles in GRI 101: Using the GRI Standards

No.

Name oforganization orindividualComment

Country

Stakeholder
group

Submission
typeOn behalf of anorganization,group orinstitution
On behalf of anorganization,group orinstitution

General comments
1For clarification to acomplish with the principles, could be listed someexamples to help some companies to acomplish them. Specially forSMEs.

AG Sustentable

Argentina

Consultant

2(3) 4. Although we do appreciate that not every disclosure can bequantified, to aid in stakeholder analysis, we strongly recommend
requiring a trend analysis of indicators to be disclosed.

PwC

UnitedKingdom

Assurance
provider3

Accuracy: GRI should add content in the Guidance section toemphasize the importance of accuracy in qualitative content of nonfinancial reports. The requirement for Accuracy uses the word
“information.” The Guidance (lines 467 – 473) refers to “qualitative” only
once, and to “data” three times. Organizations can make broad claims
and assertions that influence readers of non-financial reports.
Examples: “Acme takes all reasonable steps to eliminate forced laborand child labor from our supply chain” or “Acme’s environmental
management system ensures full compliance with laws, regulations andbinding obligations.” Auditing plays an important role in ensuring theaccuracy of claims and assertions.
Option 2 from 'factually correct and sufficiently detailed to enable theassessment of the organization’s impacts'. TO sufficiently factually

Douglas Hileman

United StatesConsultant

As an individual

Hong Kong
University of Scienceand Technology

Hong Kong

No response

No response

Accuracy

4Page 2 of 6

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correct and detailed to enable the assessment of the organization’simpacts.
REASON: 'Factually correct' implies exactly correct which is an
impractially high standard to achieve given the large number of items ina report. Consider: some items reported currently are 'estimates' rather
than 'facts'. In the future these are not allowed so I guess organisations
will need to advise they cannot determine such items sufficiently
prescisely to report them. This is not helpful
Accuracy should never be subject to the requirements of the user. The
Dr Aljaohra Altuwaijriorganisation must maintain a higher level of accuracy regardless of thetechnical literacy of the users.
Comparability(3) The new draft now focuses on changes between the current andprevious reporting period, instead of looking at all previous reporting
periods. This change is positive, as comparing to all previous reporting
periods is a requirement that creates more of a burden than a benefit tostakeholders, since the disclosures are public. However, as therequirement does not refer to significant changes, this may create moreof a burden to organizations than a benefit to stakeholders since thedisclosures are public, therefore accessible for comparison purposes.
Comparability: [cross-reference, Disclosure REP-2 Restatements … at1043 to 1075]. Comparability and Restatements. GRI should add arequirement (after Line 511) that if errors have been noted in prior years’
reporting, that the data be corrected in data provided to enable
Comparability, and that this be noted in this section. This should be restated and reinforced in Restatements. Organizations may find errors indata or qualitative information (e.g., claims or assertions) after the closeof the reporting period, or after a “final close” in preparation of the report.
These may not be corrected in time for publication of a non-financial
report for various reasons; for example, an investigation may beunderway, or regulatory authorities may be involved. Organizations may
become aware of errors or misleading statements after publication of thenon-financial report, such as from employees or other stakeholders.
These errors can affect data from one or more prior reporting periods,
such as discovery of an error in calculation of emissions or wastewater
data. Without complete, accurate reporting of information and data –including any discussed or referenced from prior reporting periods (suchSaudi Arabia

Academic

No response

ERM Certificationand Verification
Services (ERM CVS)

Netherlands

Assurance
providerOn behalf of anorganization,group orinstitution

Douglas Hileman

United States

Consultant

As an individual

Page 3 of 6

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as in graphical depictions of trends) – reports can be incorrect ormisleading. This is not consistent with a core objective of accurate,transparent non-financial reporting.
In order to guarantee the comparability of the information, wePwC
recommend for each material quantitative topic/disclosure, that thereporting of at least the current and previous year should be mandatory,
as long as that topic was material in the previous period.
However, in those cases in which the company reports a topic for thefirst time, it should not be mandatory to provide comparative informationfrom the previous period.
Completeness

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

9

Lines 541 – 543 (p. 21) Completeness (also cross-reference Lines 989
Douglas Hilemanet seq a for Disclosure REP-2 of Organization’s entities included in its
sustainability reporting, p. 40). The Universal Standards should statethat organizations should state the scope for completeness purposes,
and, where some facilities are excluded (including only for someparameters), the organization should state so at the appropriate
location(s) in the report, and provide the basis for this. The Universal
Standards and guidance state or imply that the non-financial reporting
should be complete. This is impractical in many cases, or at least forsome parameters. It may be feasible to report on some topics that are
centrally managed, and apply across the entire organization - such as
human resources policies. Some material topics may apply at larger
facilities, but not at others – such as water usage and wastewater
generation in a large organization with satellite offices or employees
working from home. “Materiality” can apply to some locations, andperhaps for some topics at those locations.
Sustainability context

United States

Consultant

As an individual10(1) We are still not clear about how to specify organization-specificsustainability norms, or standards of performance, against which suchimpacts are reported to have occurred (context-based principle)

CanadaAcademic

On behalf of anorganization,group orinstitution

11(7) •Line 566: we suggested there should be more focus on creatingsocial value without causing harm, so are pleased to see reference to‘societal expectations’.

UnitedKingdom

Charteredbody for
OSH
Professionals

On behalf of anorganization,group orinstitution

EuropeanAccounting
Association's
Stakeholder
Reporting Committee
Institution of
Occupational Safetyand Health (IOSH)

Page 4 of 6

121314151617

The PRI fully supports the inclusion of the Sustainability Context
principles, lines 558 to 580 as placing the context of an organisations
impacts against global thresholds is a very important aspect whichshould be followed through in all disclosures.
See letter

UN Principles forResponsible
Investment

UnitedKingdomMediating
institution

No response

Mediatinginstitution(2) Changing reliability to Verifiability also increase the positive pressure
towards transparency and actual demonstration of change anddisclosure.
The Universal Standards should add a requirement that “Verifiable data
includes systems and controls to prevent and detect fraud in theinformation and data included in the report.” There should be separate
bullet points in Guidance for prevention of fraud (via policies,procedures, systems, controls) and detection of fraud (often done via
monitoring, IT systems, and audits). The exposure draft referencesOECD Guidelines and UN Guiding Principles (Lines 573 – 574 andmany other instances). These – and other guidelines referenced – allaspire to ethical business conduct and reporting. Prevention anddetection of fraud is a cornerstone of financial reporting, yet fraud is not
explicitly mentioned in these publications, or explicitly in the Universal
Guidelines. Verifiability (Lines 600 – 624) does not mention prevention
or detection of fraud in the requirement or in the guidance. Prevention
and detection of fraud is essential to trustworthy information, and toenable stakeholders to make appropriate decisions about how orwhether to engage with the organization. Internal Audit (the 3LOD) and
2LOD audits (IT, environmental, quality) are key compliance and risk
mitigation activities to prevent and detect fraud.
Who are these 'individuals'?

Virginie Poulin

FranceNo response

No response

Douglas Hileman

United States

Consultant

As an individual

Dr Aljaohra Altuwaijri

Saudi Arabia

Academic

No response

The renaming/substitution of the ‘reliability’ principle as ‘verifiability’
could be confusing. It is possible that information is ‘reliable’ without
being ‘verifiable’. Reliability concerns whether the information isrepresentationally faithful. Verifiability is the susceptibility of suchinformation to independent verification. As such, these concepts are notsynonymous and should both be considered.

PwC

UnitedKingdom

Assurance
providerOn behalf of anorganization,group orinstitution

Members of theSustainability
Context Group and
r3.0
Verifiability

On behalf of anorganization,group orinstitution
On behalf of anorganization,group orinstitution

Page 5 of 6

1819(1)The requirement for Accuracy is loosely written and does not provide
enough guidance as to what the organization should do to “apply theAccuracy principle.” Specifically, The IIA recommends an additional
statement in which the organization should “provide independent,objective assurance over the accuracy of the information being reported
through an internal audit function.”
Organizations can make broad claims and assertions that influence
readers of nonfinancial reports. Internal auditing plays an important rolein ensuring the accuracy of claims and assertions. The guidance shouldemphasize the importance of accuracy in qualitative content ofnonfinancial reports.
(2)This section does not mention internal assurance. The IIA
recommends:
Edit lines 608 and 609. “Ensure that individuals other than those
involved in preparing the reported information are able to review thesupporting internal controls and documentation, with assurance provided
by an internal audit function over the controls and the information anddata included in the report.”

The Institute ofInternal Auditors

United States

Standard
setterOn behalf of anorganization,group orinstitution

The Institute ofInternal Auditors

United States

Standard
setterOn behalf of anorganization,group orinstitution

Edit to Lines 613 and 614. “If the organization designs information
systems for its sustainability reporting, design these systems in a waythat they can be examined as part of internal and external assuranceprocesses.”
The requirement and guidance would also benefit with reference tointernal controls focused on prevention or detection of fraud, essential toinformation that enables stakeholders to make appropriate decisions
about engaging with organizations.

Page 6 of 6